citizenship chapter - u.s. department of education

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CHAPTER 2Citizenship

ELIGIBLE CATEGORIES

A student must be a citizen or eligible noncitizen to receive aid from the FSA programs. The general requirement for eligible

noncitizens is that they be in the U.S. for other than a temporarypurpose with the intention of becoming a citizen or lawfulpermanent resident, as evidenced by the United States Citizenshipand Immigration Services (USCIS) in the Department of HomelandSecurity (DHS). The USCIS was briefly known as the Bureau ofCitizenship and Immigration Services or BCIS, and before that itwas the Immigration and Naturalization Service or INS. We will useDHS throughout this chapter, and we will also refer to USCIS sinceit is the actual agency that handles immigration matters and whosefield offices you and your students might have to contact. Theeligible statuses are:

• A U.S. citizen or national;

• A U.S. permanent resident;

• Citizens of the Freely Associated States: the Federated States ofMicronesia and the republics of Palau and the Marshall Islands;

• Other eligible noncitizens.

The Department of Education performs matches against theapplication to verify the student’s citizenship status. In addition, thereare procedures that you must follow to confirm a noncitizen’s statusthrough the DHS and SSA if the CPS matches don’t confirm thatstatus.

Students who are eligible because they are citizens of certainPacific Islands can only receive aid from some of the FSA programs(see “Citizens of the Freely Associated States” on p. 32). Students inthe other categories may receive any federal student aid an eligibleschool in the United States offers. If they’re attending foreign schoolsthat participate in the FFEL Program, they may receive Stafford loans.

CitizenshipHEA Sec. 484(a)(5),34 CFR 668.32(d),34 CFR 668.33,and Subpart I of Part 668.

A student has to be a citizen or eligible noncitizen to receive FSA. In thischapter we describe how the student’s FAFSA information is matched withcitizenship records. We also describe immigration documents that you mayhave to collect to make sure that the student meets this requirement.

Citizenship issues➔ U.S. citizens matched with Social Se-curity Administration (SSA) database➔ U.S. permanent residents matchedagainst DHS records➔ If the match fails after primary verifi-cation and automated secondaryconfirmation, the school must collectdocumentation and conduct manualsecondary confirmation

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Vol. 1—Student Eligibility 2005–2006

If a parent wants to take out a PLUS loan for a dependentundergraduate student, both the parent and the student must be U.S.citizens or nationals, permanent residents, or eligible noncitizens.

U.S. CITIZEN OR NATIONALThe term “U.S. citizen” includes citizens of the 50 states, the

District of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam, andthe Northern Mariana Islands. All U.S. citizens are considered to beU.S. nationals. However, not all nationals are U.S. citizens: natives ofAmerican Samoa and Swain’s Island are not U.S. citizens but arenationals and therefore may receive FSA funds.

Citizenship match with Social Security Administration (SSA)All applications are automatically matched with Social Security

records to verify name, date of birth, U.S. citizenship status, thesocial security number, and possible date of death (see chapter 4).The result of this match is reported under SSA of the match flags onthe ISIR and “SSA Citizenship Code” on the SAR.

If the student leaves the citizenship question on the FAFSA blank,the CPS will still attempt the citizenship match with the SSA. If thereis a complete match with the student’s Social Security number, name,date of birth, and U.S. citizenship, the CPS will determine the studentto be a citizen. The CPS will reject the application for insufficientinformation if one or more of the items are not provided.

Note that U.S. citizens born abroad might fail the citizenshipcheck with the SSA, unless they have updated their citizenshipinformation (see “Updating Status for Citizens Born Abroad”).

▼ Successful match. The SAR and ISIR won’t have a comment ifthe match is successful, but a match flag will indicate that thestudent’s status was confirmed.

▼ Data doesn’t match. If the student’s SSN, name, or date of birth,doesn’t match Social Security records, the citizenship status can’t beconfirmed. A comment to this effect will be printed on the outputdocument. The student should make the necessary corrections to theSSN, name, or date of birth (see Chapter 4 for a discussion of SSNmatch problems). When the corrections are sent to the CPS, the CPSperforms the match again, and you must check the new results to seeif the match confirmed the student’s citizenship status.

If you have resolved the SSN problems with the student but stillcan’t get her citizenship confirmed by the match, she can insteadprovide documentation of citizenship (see “Other documentation”).

▼ Citizenship not confirmed. If the Social Security match doesn’tconfirm that the student is a citizen, the SAR and ISIR will include acomment explaining that the student either needs to providedocuments proving citizenship or make a correction to show that sheis an eligible noncitizen.

Documenting citizenship34 CFR 668.33(c)

Data doesn’t match exampleAllen put in an incorrect number for hisSSN when he completed his FAFSA. Thenumber he used isn’t in the SSA data-base. Therefore, his application failsboth the SSN match and the SSA citizen-ship match. Allen will need to fix theproblem before he can receive aid. Be-cause the SSN is incorrect, Sarven Tech-nical Institute asks Allen to complete anew FAFSA instead of making a correc-tion (see Chapter 4 for more on fixingSSN problems).

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Ch. 2 — Citizenship

If the student is a citizen, he must give you documentation of hiscitizenship status. If it verifies that he is a citizen, you can disburseaid to him. Unlike the case of eligible noncitizens, you don’t submitthe documents to the DHS or any other agency for verification, butyou do need to keep a copy in the student’s file. The student shouldalso contact the Social Security Administration to have it update itsdatabase—something all naturalized citizens should do—but hedoesn’t have to do this to receive aid. See “Other documentation”below.

If the student is an eligible noncitizen, she must submit acorrection, which must include the Alien Registration Number orA-Number. When the correction is sent in, the CPS will attempt amatch with DHS records to confirm the student’s status.

Other documentationIf a student must prove his status as a citizen or national, you

decide what documents are acceptable. The Department doesn’tspecify them, but here are documents you might choose to use:

• A copy of the student’s birth certificate showing that she wasborn in the United States, which includes Puerto Rico (on orafter Jan. 13, 1941), Guam, the U.S. Virgin Islands (on or afterJan. 17, 1917), American Samoa, Swain’s Island, or the NorthernMariana Islands, unless the person was born to foreigndiplomats residing in the U.S.

• A U.S. passport, current or expired, except limited passports(which are typically issued for short periods such as a year andwhich don’t receive as much scrutiny as a regular passport whenapplying). In the case of nationals who are not citizens, thepassport will be stamped “Noncitizen National.”

• A copy of Form FS-240 (Consular Report of Birth Abroad), FS-545 (Certificate of birth issued by a foreign service post), or DS-1350 (Certification of Report of Birth). These are StateDepartment documents.

• A Certificate of Citizenship (N-560 or N-561), issued by USCIS toindividuals who derive U.S. citizenship through a parent.

• A Certificate of Naturalization (N-550 or N-570), issued byUSCIS through a federal or state court, or throughadministrative naturalization after December 1990 to those whoare individually naturalized.

Older versions of the Certificate of Citizenship and of theCertificate of Naturalization instruct the holder not to photocopythem. The USCIS has advised the Department that these documents(and others) may be photocopied if done for lawful purposes (suchas documenting eligibility for FSA funds).

Example: citizenship notconfirmedChavo is a U.S. citizen, but SSA doesn’tconfirm his citizenship status. SarvenTechnical Institute asks him to submitdocumentation of his status. Chavo firstsubmits a Social Security card, butSarven explains that the card doesn’tdocument his status because nonciti-zens can have Social Security cards.Chavo then brings in his U.S. passport.Sarven makes a copy of the passport forits files, and tells Chavo his citizenshiphas been documented. Sarven also ad-vises Chavo to have the SSA correct itsdatabase, so that he won’t have thisproblem again.

Social Security card and driver’slicenseA Social Security card or driver’s licenseisn’t acceptable for documenting citizen-ship or national status, since nonciti-zens and nonnationals can also havethese forms of identification.

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Updating status for citizens born abroadStudents born abroad to U.S. citizens are also U.S. citizens, and

their status is usually noted in the SSA’s database when they receivean SSN. But rarely a student’s citizenship might not be correct, andsuch a student (for example, one born on a military base abroad) willfail the citizenship match even if he has a Social Security number.He can contact the SSA to have its database corrected.

Such students can document citizenship by providing a “ConsularReport of Birth Abroad” (Form FS-240, which is proof of U.S.citizenship) or a “Certification of Report of Birth” (Form DS-1350,which is evidence of U.S. citizenship and equivalent to a birthcertificate). If the birth of the student was registered with theAmerican consulate or embassy in a foreign country before he turned18, he can receive a copy of one of the above by sending a written,notarized request to the State Department at

Vital Records SectionPassport Services1111 19th Street, NW, Suite 510Washington, DC 20522-1705202-955-0307

The student should provide his name given at birth, the date andlocation of birth, the parents’ names, available passport information,a return address, and a daytime phone number. The signature and acopy of valid photo identification of the requester must be included.For form FS-240 the student also has to include the original form (toexchange it) or a signed, notarized affidavit that the original wasdestroyed or lost. The FS-240 is $30, and the DS-1350 is $30 plus $20for each additional copy. This should be sent as a check or moneyorder (no cash or foreign checks) payable to The Department ofState. It will take four to eight weeks to receive the form.

If the student is over 18 and the birth wasn’t registered, she canfile a self-petition for a “Certificate of Citizenship” to any local USCISoffice (Form N-600). Proof of the parents’ U.S. citizenship at the timeof the student’s birth must be provided.

U.S. PERMANENT RESIDENTS AND OTHER ELIGIBLENONCITIZENS

A lawful permanent resident (LPR) is a noncitizen who is legallypermitted to live and work in the United States permanently. Othereligible noncitizens include:

• Refugees. This status is considered temporary, althoughrefugees can apply for permanent residence;

• Persons granted asylum. Persons who have been granted asylumin the United States are given employment authorization forone year. At the end of that year, they are eligible to apply forpermanent residence. Asylum status continues unless revokedby DHS or until permanent residence status is granted;

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• Conditional entrants. These individuals are refugees whoentered the United States under the seventh preferencecategory of P.L. 89-236 or whose status was adjusted to lawfulpermanent-resident alien under that category. Note that theDHS stopped using this category on March 31, 1980;

• Persons paroled into the U.S. for at least one year. Theseindividuals must also provide evidence (such as having filed avalid permanent resident application) from the DHS that theyare in the U.S. for other than a temporary purpose and intendto become a citizen or permanent resident;

• Cuban-Haitian entrants.

Some noneligible statuses are:

• Family unity status. Such individuals have been granted relieffrom deportation under the Family Unity Program. Previouslythey were eligible for FSA funds.

• Temporary residents. These individuals are allowed to live andwork in the U.S. under the Legalization or Special AgriculturalWorker program. Previously they were eligible for FSA funds.

• Individuals with nonimmigrant visas. This includes those withwork visas, and students, visitors, and foreign governmentofficials.

MATCH WITH DHS RECORDSTo verify the immigration status of U.S. permanent residents and

other eligible noncitizens, the Department collects A-Numbers on theFAFSA. (The DHS assigns A-Numbers to all legal immigrants.) If theapplicant indicates on the FAFSA that he is an eligible noncitizen andprovides an A-Number, identifying information from the FAFSA isautomatically sent to the DHS for “Primary Verification.”

The results of the match are shown by a match flag in the FAAinformation section of the output document, under the heading “DHS” onthe ISIR or “DHS Match Flag” on the SAR. There will also be a commentabout the results on the output document.

Because all applications are matched with SSA records, anapplication that is matched with DHS records will also be matched withcitizenship information from the SSA. Results from the DHS match takeprecedence over any results from the SSA match, so the latter’s citizenshipmatch flags won’t appear on the output document. You should follow theusual procedures for resolving any DHS match discrepancies.

If a student leaves the citizenship question blank but provides anA-Number, the CPS will assume the applicant is an eligible noncitizenand will attempt to match the A-Number with DHS records. If thestudent leaves both the citizenship question and A-Number blank, the

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CPS won’t match with DHS records and will reject the application.The student must submit a correction with the citizenship status and A-Number if he is an eligible noncitizen.

▼ Successful match. If the match confirms the student’simmigration status, then he can receive aid if the other eligibilitycriteria are also met. The SAR and ISIR with the successful matchresults are documentation of the student’s eligibility. Of course, if youhave other information about his status that seems to contradict thesuccessful match result, you must resolve the conflict before paying thestudent (see “Conflicting Information” in chapter 1).

▼ Not enough information. If the student said she was an eligiblenoncitizen but provided either no A-Number or an illegible or invalidone, the match won’t be attempted. Instead, the student will receive aC code and a comment stating that there’s a question about the A-Number and directing her to provide the school with documentationof her eligibility. Compare the document with the SAR/ISIR; ifappropriate, the student should correct the A-Number and resubmitit so that the match can be conducted.

Note that the same will apply to citizens of the Marshall Islands,the Federated States of Micronesia, and Palau because such studentswon’t have A-Numbers to report. However, these students aren’trequired to provide proof of eligible noncitizen status.

▼ Status not confirmed. If the match was conducted but didn’tconfirm the student’s status, the discrepancy must be resolved beforeyou pay him. (First make sure that his alien registration numberand date of birth are correct.) To confirm he is eligible for FSAfunds, his record will have to pass through a subsequent processcalled secondary confirmation.

AUTOMATED SECONDARY CONFIRMATIONIf the database match with immigration records doesn’t confirm

a student’s claim to be an eligible noncitizen, the DHS will automaticallycheck if it has documentation that determines the student’s citizenship.If this automated process confirms a student’s eligible noncitizen status,the process obviates the manual or paper secondary confirmation thatuses the G-845S form.

The CPS will wait for up to three days to give the DHS time toconduct the automated secondary confirmation. If after three daysthe DHS has not been able to confirm the student’s citizenshipstatus, the CPS will process SARs and ISIRs with a secondaryconfirmation match flag value of “P”, meaning that the procedure isstill in progress. Once the DHS finishes the confirmation, the CPSwill generate SARs and ISIRs reporting the results.

The school should wait at least five but no more than 15business days for the result of automated secondary confirmation.

The A-Number on the FAFSA andthe DHS verification numberWhen the CPS matches with DHSrecords, a 15-digit verification numberis assigned to the student andprinted in the “FAA Information” sec-tion of the SAR and ISIR. This num-ber is needed for secondary confir-mation with the DHS (see “SecondaryConfirmation”) and is reported inbox 6 of the G-845S form. If the stu-dent does not provide an A-Numberon the FAFSA, the match can’t bemade and the student won’t receivea DHS verification number. Thestudent’s information should be re-submitted with the A-Number so thata computer match may be attemptedbecause the school won’t be able tocheck the student’s status through thesecondary process unless it has a DHSverification number.

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If the result has not been received by that time, the school mustbegin the paper process.

A correction made while the DHS is conducting the automatedsecondary confirmation will start the process over, i.e., the correctionwill be sent through primary confirmation. Though unlikely, if the newprimary confirmation match yields a “Y,” the transaction can be used toaward aid. A correction made to a transaction that containssecondary confirmation results of “Y” or “C” (or a transaction with aprimary confirmation result of “Y”) will not be sent through theDHS citizenship match again. Otherwise the record will be re-sentfor matching.

PAPER SECONDARY CONFIRMATION If the student didn’t pass automated secondary confirmation or

if you have conflicting information about his immigration status, youmust use paper secondary confirmation. The student has to give youdocumentation showing that he is an eligible noncitizen. If youdetermine that this documentation doesn’t provide reasonableevidence that he is an eligible noncitizen, he isn’t eligible for FSAfunds. However, if the student provides documentation that appearsto demonstrate that he is an eligible noncitizen, you must submit thedocumentation to the USCIS (in the DHS) to confirm it is valid.

Documents that establish aid eligibilityThe standard documentation for a permanent resident of the

United States is the Permanent Resident Card (Form I-551, since1997) or Resident Alien Card (Form I-551, before 1997). Both formsare referred to colloquially as “green cards,” though they are notgreen. The DHS is replacing cards issued before 1979 with these new,counterfeit-resistant cards. The deadline established for permanentresidents to replace their old cards was March 20, 1996. However, theolder Alien Registration Receipt Card (Form I-151, issued prior toJune 1978) remains acceptable as evidence of permanent residencefor the purpose of receiving FSA funds.

Permanent residents may also present an Arrival/DepartureRecord (Form I-94) with one of the following endorsements:

• “Processed for I-551. Temporary Evidence of Lawful Admissionfor Permanent Residence. Valid until ____________.Employment Authorized.”

• “Temporary Form I-551. Admission for permanent residence at_______________[port] on ______________ [date] verified._________________ [signature of issuing officer] _________[title].” This I-94 will also contain the individual’s photo and anINS seal over the photo and the stamp.

The I-94 will have an A-Number annotated on it and is anacceptable document as long as the expiration date has not passed. Anoncitizen’s passport will also have an A-Number annotated on it and

Automated secondaryconfirmation comment codes“Y”: citizenship status confirmed. Thestudent is eligible for aid.

“C”: in continuance. The DHS hasnot yet been able to confirm that thestudent is an eligible noncitizen.The school is encouraged but notrequired to wait ten business daysfor another ISIR with an updatedmatch result. If there is no update,the school begins the paper (G-845S) secondary confirmation pro-cess.

“N”: citizenship not confirmed. TheDHS did not confirm the student’scitizenship status as eligible. Theschool should begin paper second-ary confirmation.

“X”: DHS needs more information.The school should begin paper sec-ondary confirmation.

School policies on secondaryconfirmation34 CFR 668.134

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may contain one of the endorsements above, but the passport aloneisn’t sufficient documentation for receiving aid.

For other classes of eligible noncitizens, the most commonlypresented evidence of their status is on the I-94, which will containone of the following:

• Refugees. A stamp reading either “Admitted as a RefugeePursuant to Section 207 of the Act. If you depart the UnitedStates you will need prior permission to return. EmploymentAuthorized,” or “Status changed to refugee pursuant to Section207 (c)(2) of the Immigration Nationality Act, on ___________.Employment Authorized.” Refugees may also have a RefugeeTravel Document (Form I-571), which can be used fordocumentation if it’s unexpired.

• Asylees. A stamp reading “Asylum status granted pursuant toSection 208, USCIS. Valid to ________________. EmploymentAuthorized.”

• Conditional entrants. A stamp indicating that the student hasbeen admitted to the United States as a conditional entrant.Because the DHS stopped using this category after March 31,1980, you should not disburse FSA funds if the student has an I-94 with conditional-entrant status granted after that date.

• Parolees. A stamp indicating that the student has been paroledinto the United States for at least one year, with a date that hasnot expired. (Federal student aid cannot be disbursed after thedocument has expired.)

• Cuban-Haitian entrants. A stamp across the face of the I-94indicating that the student has been classified as a “Cuban-Haitian Entrant (Status Pending). Reviewable January 15, 1981.Employment authorized until January 15, 1981.” Note that adocument showing that the holder is a Cuban-Haitian entrant isvalid even if the expiration date has passed.

The stamps described above will be in a rust-colored ink and willnormally contain a validation indicating the office of issuance and acode that indicates which officer prepared the document. Examplesof codes are “WAS-82” (Washington District Office, Officer Number82) or “1/13/84 SPO.KD” (Spokane Office, officer’s initials KD).

You must keep in the student’s file a copy of the immigrationdocumentation the student submits, along with the secondaryconfirmation results received from the USCIS. Documentationprovided as proof of the student’s immigration status (such as the I-551 and I-94) may legally be photocopied by the student as long as thephotocopies are made for this lawful purpose. The student mustunderstand that he is permitted to photocopy a USCIS document onlyfor lawful purposes such as applying for FSA funds. (Documentphotocopying is generally not permitted for other purposes.)

Status not confirmed exampleOn his original application Hector didn’tgive his A-Number and reported thathe was a citizen. When the SSA didn’tconfirm this, Hector told the FAA atGuerrero University that he was apermanent resident. He made acorrection, but the USCIS didn’t confirmhis status as an eligible noncitizen. Heexplained to the FAA that he hadapplied for permanent resident statusbut didn’t have documentation yet. TheFAA told him that when he haddocumentation that his application wasapproved, he should bring it to Guerreroso that it could be submitted to theUSCIS for confirmation.

Conditions requiring secondaryconfirmation34 CFR 668.133(a)

Use of copy of I-94Note that a refugee or an asylee mayapply for permanent-resident status.During the period in which theapplication is being reviewed, thestudent may have a copy of the I-94that includes the endorsement “209a (or209b) pending. EmploymentAuthorized.” Students with this form ofdocumentation are eligible for FSAfunds as long as the I-94 has notexpired.

Documentation for Cuban-Haitian entrantsThe I-94 for some Cuban-Haitianentrants who are applying forpermanent residence may be stamped“applicant for permanent residence.”(Or the student may instead be given aseparate document acknowledging thereceipt of his or her application forpermanent residence.) Because theapplication for permanent residence isnot sufficient to make a student eligiblefor FSA funds, a student who is aCuban-Haitian entrant must requestdocumentation of that status from theUSCIS.

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You must always examine and copy original documents.Sometimes the endorsement or stamp does not photocopy well due tothe ink color on the original document. In this case you should handcopy the exact endorsement on the photocopy. Because theendorsement can be placed anywhere on the I-94, the endorsementmay be difficult to locate. Note that although the endorsement mayappear on the student’s passport, the endorsement must also be onthe I-94. Because USCIS offices don’t have uniform procedures orstamps, you should contact the local office with questions regardingacceptable immigration documentation.

Special circumstancesIf the student has an I-551 with a baby picture, she should update

the I-551 with the USCIS. Permanent residents are expected to get anew picture and be fingerprinted at the age of 14. However, you cansubmit the documents to USCIS and ultimately pay a student who hasan I-551 with a baby picture as long as you can confirm that the I-551belongs to the student. You can confirm this by comparing the I-551to a current photo ID that has the student’s name, date of birth, andsignature. The current photo ID must also be consistent with anyidentifying information that you keep in the student’s file.

A student who has an approved application for permanentresidence on file with the USCIS and who is waiting for a permanentresident card may not have proof of her permanent resident status.She should contact her local USCIS office for the passport stamp or I-94 stamp described at the end of this chapter, as these are available toa student before the normal permanent resident documentation isissued. Note that an application for permanent resident status is notsufficient for determining eligibility for FSA funds.

The Marriage Fraud Amendments established a two-yearconditional permanent resident status for certain alien spouses andtheir children. The alien spouse of a U.S. citizen or legal immigrant isgiven conditional permanent resident status if the marriage took placeless than two years before the spouse applied for permanent residentstatus or citizenship. This status may also apply to any of the spouse’schildren who are aliens.

An alien who is granted conditional permanent resident status willbe given a Form I-551. This is the same I-551 that is issued to regularpermanent residents, except that the card for a conditional permanentresident expires in two years, as opposed to ten years for the regularcard. A conditional permanent resident must file a petition forremoval of this restriction in the 90 days before the end of the twoyears. The USCIS will review the petition and, if the result of thereview is satisfactory, drop the restriction and issue new documents.Conditional permanent residents holding a valid I-551 are eligible toreceive FSA funds until the expiration date.

If a person is applying to suspend deportation, she must request ahearing before an immigration law judge who will render an oral or

Jay TreatyThere is one unusual circumstancewhere you will need to collectdocumentation from the student withoutrequiring secondary confirmation. TheJay Treaty of 1794 (as well assubsequent treaties and U.S.immigration law) gives Canadian-bornNative Americans with “50% Indianblood” the legal right to live and work inthe United States. Such individuals arenot subject to the legal restrictionstypically imposed on aliens by the DHS,are not required to obtaindocumentation from the DHS, and areconsidered “lawfully admitted forpermanent residence.”

Because few FSA applicants are eligibleunder the Jay Treaty, the FAFSA does notinclude a separate response for suchstudents. Therefore, any student eligiblefor FSA funds through the Jay Treatyshould report that he or she is an“eligible noncitizen” and fill in“A999999999” for the A-Number. Thestudent will fail the match and acomment 144 will be printed on theoutput document. The school mustobtain proof that the student has 50%Native American blood and was born inCanada. To do so, the student shouldprovide one or more of the followingdocuments:

• A “band card” issued by the BandCouncil of a Canadian Reserve, or bythe Department of Indian Affairs inOttawa;

• Birth or baptism records;

• An affidavit from a tribal official orother person knowledgeable about theapplicant’s or recipient’s family history;

• Identification from a recognized NativeAmerican provincial or territorialorganization.

If the student can provide one of theabove forms of documentation, and isotherwise eligible, the school mustdocument the file and can award FSAfunds.

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written decision. If the decision is favorable, the USCIS will give theapplicant a Form I-551, which will certify her lawful permanentresident status. Therefore, there is no special category for personswho have been granted suspensions of deportation.

Documents showing ineligible statusesIf the document a student submits is for a noneligible status, you

shouldn’t submit the documentation for secondary confirmation. TheUSCIS can only confirm whether or not the documentation isgenuine; it doesn’t determine whether the student is eligible for FSAfunds. Unless the student can submit documentation for an eligiblestatus, as described above, the student can’t receive aid.

An approved Form I-797, “Application for Voluntary DepartureUnder the Family Unity Program,” indicates that the student has beengranted relief from deportation under the Family Unity Program.Students with this status are no longer eligible for aid.

The Immigration Reform and Control Act of 1986 (IRCA)established a legalization program (also called the amnesty program)for certain illegal aliens. The alien might eventually be grantedpermanent resident status. Although these individuals were givendocumentation that allowed them to work while their application wasbeing processed, they aren’t eligible for aid until their application forpermanent resident status is approved. Documents such an individualmight have in the interim are the Employment Authorization Card(Form I-688A), Employment Authorization Documents (Form I-688Bor the I-766), or the Temporary Resident Card (Form I-688). None ofthese documents qualifies the student for FSA eligibility.

A student with a nonimmigrant visa isn’t eligible for FSA fundsunless he or she has a Form I-94 with one of the endorsements listedearlier. Nonimmigrant visas include the F-1, F-2 or M-1 Student Visa, B-1 or B-2 Visitor Visa, J-1 or J-2 Exchange Visitors Visa, H series or Lseries Visa (which allow temporary employment in the U.S.), or a Gseries Visa (pertaining to international organizations). Also, someonewho has only a “Notice of Approval to Apply for Permanent Residence(I-171 or I-464)” cannot receive FSA funds.

Some students may present Forms I-94 stamped “TemporaryProtected Status.” This status is used for persons who are fromcountries that are in upheaval, but the status differs significantly from“Refugee” or “Asylee” because it provides no conversion to permanentresident status. A student with this status is not eligible for FSA funds.

Using the G-845S for secondary confirmationTo initiate paper secondary confirmation, you must complete a

Form G-845S and send it to the USCIS field office for your areawithin 10 business days of receiving the student’s documentation.The G-845S (“Document Verification Request”) is a standard form thatasks the USCIS to confirm the noncitizen’s immigration status.

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To complete the G-845S, fill in each item on the top half of theform. You must enter the A-Number in box 1. For box 6 you mustprovide the 15-digit DHS verification number that is printed on theSAR and ISIR. Secondary confirmation requests without this numberwill be returned unprocessed. “Education Grant/Loans/Work Study”must be marked in box 8, “Benefits.” You must state your name as thesubmitting official and your school’s name as the submitting agency.

Photocopies of the front and back sides of the student’simmigration document must be attached to the G-845S. Be sure tosubmit each pertinent visa and immigration document along with theform; the G-845S submitted by itself can’t be used to determine FSAeligibility. A student who lost documents or surrendered them whenentering prison is responsible for getting copies of them before the G-845S is submitted. (See “Replacing Lost DHS Documents” on p. 35.)You can request copies of immigration documents directly from penalinstitutions at the request of the student. Send the completed G-845Sand attachments to the field office serving the prison’s locale.

Noncitizens may also present other pertinent documents, suchas marriage records or court orders, that indicate the identity orUnited States residency of the holder. Although these documentsmay not serve as adequate proof of immigration status, copies ofthem should be submitted with the G-845S, as they may be useful tothe status verifier.

A status verifier at the district USCIS office will search the student’srecord to confirm his immigration status, complete the “INSResponse” section (the form still uses “INS” because it has not yetbeen updated), and send the G-845S back to your office, generallywithin ten working days of receipt. We recommend that youdocument any mailings to the USCIS and, if you haven’t heard back,that you call its office to make sure the G-845S was received. If youdon’t receive a response from the USCIS within 15 working days (tenworking days plus five days’ mail time) of the date you sent the G-845S, you should review the file and use your best judgment todetermine whether the student meets the eligible noncitizenrequirements based on the documentation the student provided andthe information in this chapter. If you believe that the student meetsthe requirements, you can make any disbursement for which thestudent is otherwise eligible; however, you must note in the student’sfile that USCIS exceeded the time allotment and that noncitizeneligibility was determined without their verification.

When secondary confirmation results in an eligible status, youmust keep the G-845S. If the confirmation process indicates adiscrepancy, you must ask the student to correct the discrepancy withthe USCIS. No certification of loans or further disbursement of fundscan be made until the discrepancy is corrected. If the discrepancy isn’treconciled, the student must repay all aid except wages earned underFWS. Whenever the student is able to provide new information, itmust be submitted to the USCIS on a new G-845S.

Contacting the USCIS/DHSSend the G-845S to the USCIS field of-fice that serves your area. This will beeither a district office or a sub office.You can get the address by calling theUSCIS at 1-800-375-5283 or by visitingtheir website at http://uscis.gov andlooking under field offices.

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As long as you have followed the procedures outlined here,including notifying the student of the discrepancy and withholdingfurther payments and loan certifications as soon as a discrepancy isfound, your school isn’t liable for aid disbursed prior to secondaryconfirmation. (This, of course, assumes that you had no otherconflicting information prior to making the disbursement and hadreviewed the available documentation and concluded that the studentwas otherwise eligible.)

Interpreting the USCIS responseThe status verifier will mark one or more of the checkboxes on the

G-845S. The following list explains for each checkbox whetherchecking the box means the student is eligible. In reviewing thecompleted G-845S, bear in mind that it reflects the student’s mostrecent status with the USCIS and may show a different status than thedocumentation presented by the student. In this case, you shouldverify that both documents identify the same person. If so, the statuson the G-845S should be used since that status is the most current.

1. This document appears valid and relates to a LawfulPermanent Resident alien of the United States. Block #1 ischecked when the documentation submitted is determinedto be a valid I-551, I-151, or I-94, or a passport stamped withthe notation “Processed for I-551, Temporary Evidence ofLawful Admission for Permanent Residence.” A student withthis status is eligible for FSA aid.

2. This document appears valid and relates to a ConditionalResident alien of the United States. This is checked whenthe documentation submitted is determined to be a valid I-551, or I-94 or a passport stamped with the notation“Processed for I-551, Temporary Evidence of LawfulAdmission for Permanent Residence.” A student with thisstatus is eligible for FSA aid.

3. This document appears valid and relates to an alienauthorized employment as indicated below. This is checkedto indicate whether the authorization covers full-time orpart-time employment and when, if applicable, the period ofemployment will expire. “Indefinite” will be indicated ifthere is no specific expiration date for employmenteligibility. Employment authorization by itself doesn’t meanthat the student is eligible for FSA funds. Unless some othereligible status is also checked, or the student can provideother documentation that can be confirmed by the USCIS,the student isn’t eligible for FSA aid.

4. This document appears valid and relates to an alien who hasan application pending for...: This is checked when an alienis waiting for a new immigration status or a change ofimmigration status. If a change of status is pending, theappropriate block indicating the current status will also bechecked elsewhere on the G-845S. A pending application

School policies and procedureson secondary confirmation34 CFR 668.134–135

Determining eligibility if USCIS re-sponse is late34 CFR 668.136(b)

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for an immigration status doesn’t (by itself) make thestudent eligible for FSA funds. To be eligible, the studentmust have an eligible status checked on the form, or provideother documentation of an eligible status.

5. This document relates to an alien having been grantedasylum/refugee status in the United States: This is checkedwhen an alien has been granted asylum or refugee status inthe United States. Documentation presented may includeeither Form I-94 stamped with “Section 207-Refugee” or“Section 208-Asylee” or a Refugee Travel Document (Form I-571). A student with this status is eligible for aid.

6. This document appears valid and relates to an alien paroledinto the United States pursuant to Section 212 of the I&NAct: This is checked for parolees, of which there are a feweligible classes. Documentation presented may includeForm I-94 stamped with “Section 212(d)(5) - Parolee.” Thestudent is eligible for aid if paroled into the U.S. for at leastone year and if he has evidence from the DHS (such ashaving filed a valid permanent resident application) that heis in the U.S. for other than a temporary purpose andintends to become a citizen or permanent resident.

7. This document appears valid and relates to an alien who is aCuban-Haitian entrant: This is checked for Cubans whoentered the United States illegally between April 15, 1980and October 10, 1980 and Haitians who entered the countryillegally before January 1, 1981. A student with this status iseligible for FSA aid.

8. This document appears valid and relates to an alien who is aconditional entrant: This is checked for conditional entrantsunder the old provisions of P.L. 89-236. Documentationpresented may include Form I-94 stamped with “Section203(a)(7).” Noncitizens who fall into this category had to haveentered the United States prior to the enactment of theRefugee Act of 1980. A student with this status is eligible foraid.

9. This document appears valid and relates to an alien who is anonimmigrant. This is checked to indicate an alien who istemporarily in the United States for a specific purpose. Thiscategory includes students, visitors, and foreign governmentofficials. Documentation presented may include the Form I-94. Students with this status aren’t eligible for aid.

10. This document appears valid and relates to an alien notauthorized employment in the United States: This block ischecked when an alien’s status prohibits employment in theUnited States. Students with this status aren’t eligible for aid.

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11. Continue to process as legal alien. INS is searching indicesfor further information. This block is checked if the USCISis withholding judgment, pending further investigation onthe status or validity of documentation. This statementdoesn’t imply that the applicant is an illegal alien or theholder of fraudulent documentation. Benefits shouldn’t bedenied on the basis of this statement.

The student’s documentation should be accepted at facevalue until the USCIS sends final notification regardingimmigration status. If the student appears to be an eligiblenoncitizen based upon your review of the documents, youmay pay the student any FSA funds for which she is eligible.If the USCIS later notifies you that the student’sdocumentation isn’t valid, you must cancel furtherdisbursements, but your school isn’t liable for the paymentsalready made—the student is.

12. This document is not valid because it appears to be...: This ischecked when the document has expired or when it appearsto be counterfeit or altered (there are checkboxes toindicate which of these applies). Notify the student thatunless corrective action is taken with the USCIS, the case willbe submitted to the Office of Inspector General (OIG).Until this discrepancy is resolved, no further aid may bedisbursed, awarded, or certified. If the student does nottake corrective action in a timely manner, you must reportthe case to the OIG. Note, however, that students whoseLPR card has expired are still lawful permanent residents,and if there are no other problems, they should not bereported to the OIG, but they should update their card.

Citizenship and Immigration Services will initial and stamp thefront of the G-845S in the signature block.

The comments block on the back of the G-845S provides furtherinstructions. The intended meaning of each of the following blocksthat may be checked follows:

13. No determination can be made from the informationsubmitted. Please obtain a copy of the original alienregistration documentation and resubmit. This is normallychecked when you haven’t provided copies of any of theUSCIS documents. You should resubmit the G-845S withcopies of the original alien documentation.

14. No determination can be made without seeing both sides ofthe document submitted. Resubmit the G-845S with copiesof both sides of each document.

15. Copy of document is not readable. Resubmit the G-845Swith higher quality copies of the original aliendocumentation.

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SAVE

Section A > to be completed by the submitting agency.

OMB #1115>0122

Document Verification Request

To: Immigration and Naturalization Service

From: Typed or Stamped Name and Address of Submitting Agency

Attn: Status Verifier

(INS may use above address with a #20 window envelope.)

1. Alien Registration or I>94 Number

2. Applicantπs Name (Last, First, Middle)

3. Nationality

4. Date of Birth (Month/Day/Year)

5. Social Security Number

1. " This document appears valid and relates to aLawful Permanent Resident alien of theUnited States.

2. " This document appears valid and relates to aConditional Resident alien of the UnitedStates.

3. " This document appears valid and relates to analien authorized employment as indicatedbelow:a. " Full>Timeb. " Part>Timec. " No Expiration (Indefinite)d. " Expires on

(specify Month/Day/Year, below)

4. " This document appears valid and relates to analien who has an application pending for(specify INS benefit below)

5. " This document relates to an alien having beengranted asylum/refugee status in the UnitedStates.

6. " This document appears valid and relates to analien paroled into the United States pursuant toSection 212 of the I&N Act.

7. " This document appears valid and relates to analien who is a Cuban/Haitian entrant.

U.S. Department of JusticeImmigration and Naturalization Service

6. Verification Number

7. " Photocopy of Document Attached.

(If printed on both sides, attach a copy of the front and of the

back.)

" Other Information Attached (Specify documents).

8. (Benefit) (Your Case Number)

" AFDC

" Education Grant/Loans/Workstudy

" Food Stamp

" Housing Assistance

" Medicaid/Medical Assistance

" Unemployment Insurance

" Employment Authorization

" Other (specify)

9. Name of Submitting Official

10. Title of Submitting Official

11. Date

12. Telephone Number

8. " This document appears valid and relates to analien who is a conditional entrant.

9. " This document appears valid and relates to analien who is a nonimmigrant(specify type or class below)

10. " This document appears valid and relates to analien not authorized employment in the UnitedStates.

11. " Continue to process as legal alien. INS issearching indices for further information.

12. " This document is not valid because it appears tobe (check all that apply)

a. " Expiredb. " Alteredc. " Counterfeit

" Please see reverse for additional comments.Form G>845S (Rev. 06/06/89) Y

INS Stamp

Section B > to be completed by INS

INS RESPONSE: From the documents or information submitted and/or a review of our records we find that:

� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

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� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

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� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

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1–30


Comments13. " No determination can be made from the information submitted. Please obtain a copy of the original alien

registration documentation and resubmit.

14. " No determination can be made without seeing both sides of the document submitted (please resubmit request).

15. " Copy of document is not readable (please resubmit request).

™PRUCOL∫

For Purposes Of Determining If Alien Is Permanently Residing Under Color Of Law Only!

16. " INS actively pursues the expulsion of an alien in this class/category.

17. " INS is not actively pursuing the expulsion of an alien in this class/category, at this time.

18. " Other

Instructions

f Submit copies of both front and back of alienπs original documentation.

f Make certain a complete return address has been entered in the ™From∫ portion of the form.

f The Alien Registration Number (™A∫ Number) is the letter ™A∫ followed by a series of (7) or (8) digits. Also in thisblock may be recorded the number found on Form I>94. (Check the front and back of the I>94 document and if the™A∫ Number appears, record that number when requesting information instead of the longer admission number asthe ™A∫ Number refers to the most integral record available.)

f If Form G>845 is submitted without copies of applicantπs original documentation, it will be returned to thesubmitting agency without any action taken.

f Address this verification request to the local office of the Immigration and Naturalization Service.

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The comments listed under “Permanently Residing Under Colorof Law” (PRUCOL) reflect information about aliens who have appliedfor special treatment (for example, by virtue of having life-threateningmedical situations) that may cause the DHS to refrain from seekingtheir expulsion. These blocks will be checked only if a request forevaluation for PRUCOL is made in Block 8 on the first page of the G-845S. Comments will rarely be made in this section because youwouldn’t have asked for a PRUCOL evaluation when submitting the G-845S. However, in all cases, the USCIS should check other responseson the form as well, and these other responses should be used todetermine the student’s status.

Student rightsYou must allow the student at least 30 days from the time you

receive the output document to provide documentation of hisimmigration status. During this period and until the results of thesecondary confirmation are received, you can’t deny, reduce, orterminate aid to him. If the documentation supports the student’sstatus as an eligible noncitizen, and if at least 15 business days passedsince the date on which the documentation was submitted to theUSCIS, you can disburse aid to an otherwise eligible student pendingthe USCIS response.

Your school isn’t liable if you erroneously conclude that a studentis an eligible noncitizen, provided that you had no conflicting data onfile and you relied on:

• a SAR or ISIR indicating that the student meets therequirements for federal student aid,

• a USCIS determination of an eligible immigration status inresponse to a request for secondary confirmation, or

• immigration status documents submitted by the student, if theUSCIS did not respond in a timely fashion.

The student (or parent for PLUS borrowers) is liable for any FSAfunds received if he is ineligible. If you made your decision withouthaving one of these types of documents, your school is held responsible forrepaying FSA funds to the Department.

Your school should establish procedures to ensure due process forthe student if FSA funds are disbursed but the aid office laterdetermines (using secondary confirmation) that the student isn’t aneligible noncitizen. The student must be notified of his ineligibilityand given an opportunity to contest the decision by submitting toyour school any additional documents that support his claim to be aneligible noncitizen. If the documents appear to support the student’sclaim, you should submit them to USCIS using paper secondaryconfirmation. You must notify the student of your office’s finaldecision, based on the secondary confirmation results.

Procedures when ineligibility isdetermined after disbursement34 CFR 668.136(c)

Lack of response exampleMikko is a refugee, and received aidfrom Guerrero University for the 2004-2005 school year. His status wasn’tconfirmed through the DHS match, soGuerrero had to perform secondaryconfirmation. The DHS didn’t respond intime, so Guerrero paid Mikko withoutany response. When Mikko applies for2005-2006, the CPS still doesn’t confirmhis status. Even though Guerrerobegan secondary confirmation forMikko last year and his documentshaven’t expired, because the schoolnever received a DHS response, it mustperform secondary confirmation again.

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For every student required to undergo secondary confirmation,you must furnish written instructions providing:

• an explanation of the documentation the student must submitas evidence of eligible noncitizen status. (See the “SummaryChart of Acceptable Documentation.”);

• your school’s deadline for submitting documentation (whichmust be at least 30 days from the date your office receives theresults of the primary confirmation);

• notification that if the student misses the deadline, he may notreceive FSA funds for the award period or period of enrollment;and

• a statement that you won’t decide the student’s eligibility untilhe has a chance to submit immigration status documents.

CITIZENS OF THE FREELY ASSOCIATED STATESStudents who are citizens of the Freely Associated States (Palau,

the Republic of the Marshall Islands, and the Federated States ofMicronesia) are eligible for Pell grants, FWS, and FSEOG but arenot eligible for FSA loans (see also the margin note); they shouldindicate on the FAFSA that they are eligible noncitizens and leave theA-Number item blank. If the student doesn’t have an SSN, he canleave that item blank as well. Because he isn’t giving an A-Number, hisapplication won’t go through the DHS match. As long as his filecontains consistent information on his citizenship, you aren’t requiredto collect documentation.

Citizens of the Freely Associated States who file through EDExpressmay indicate that they are eligible noncitizens, after which their stateof legal residence will be confirmed. If they are determined to beresidents of the Freely Associated States, they won’t be required toprovide an A-Number, and EDExpress won’t reject their applications.

DOCUMENTING IMMIGRATION STATUSIN LATER AWARD YEARS

There are several cases in which you must document a student’simmigration status in a subsequent award year if that student again isnot confirmed through the application process.

For example, a student who presented a Temporary Form I-551 ina prior award year should have received a permanent I-551 by the nextyear and shouldn’t still have a temporary card. You should refer thestudent to USCIS to obtain a permanent I-551 or an updatedendorsement on the previous card. The documents should also besubmitted to USCIS on a G-845S.

You must also document the eligible noncitizen status each awardyear for a conditional permanent resident, a refugee, a Cuban-Haitian

Citizens of the Freely AssociatedStatesThe Compact of Free Association (P.L.99-239) created three political entitiesfrom the former Trust Territory of the Pa-cific Islands. Two of these entities, theMarshall Islands and the FederatedStates of Micronesia, voted in 1986 toend political ties with the United States.The third entity, Palau, voted to ratify thecompact in 1994; its independence waseffective October 1, 1994. These threeentities are the Freely Associated States.34 CFR 600.2

Losing FSEOG and FWSThe Compact of Free AssociationAmendments Act of 2003, or the Com-pact Act, eliminates eligibility for citi-zens of the Republic of the Marshall Is-lands and the Federated States ofMicronesia for FSEOG and FWS money.(The citizens of Palau are subject to adifferent compact and remain eligible.)To mitigate this loss, the Compact Actalso sets up a Supplemental EducationGrant (SEG) program for relevant stu-dents. These new grants will first beawarded in the 2005 fiscal year. Stu-dents who are citizens of the abovestates will continue to be eligible forFWS and FSEOG for up to four aca-demic years after December 17, 2003,provided they were attending an insti-tution of higher education on that datein the United States or its territories, theFederated States of Micronesia, or theRepublic of the Marshall Islands. Ifthey were not in such attendance, theyare not eligible for FWS and FSEOG.

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entrant, or a person granted asylum. Students in any of thesecategories may have been redesignated to permanent-resident statusor may have had their statuses revoked. You will have to send thedocuments for secondary confirmation if the student’s status isn’tconfirmed through the USCIS match.

You don’t have to document a student’s eligible noncitizen statusin subsequent award years if you’ve documented that the student is aU.S. citizen or national, is a citizen of the Freely Associated States, orhas a Form I-551 or I-151.

In addition, you aren’t required to perform secondaryconfirmation if for a previous award year it showed that the studentwas an eligible noncitizen and the documents used for that secondaryconfirmation haven’t expired. You must also have no conflictinginformation or reason to doubt the student’s claim of having eligiblenoncitizen status. Also note that you must have confirmed the statusin a previous award year. (Although you can disburse aid without theUSCIS response if the USCIS doesn’t respond in time, you can’t countthat lack of response as confirmation for the following year.)

REPLACING LOST DHS DOCUMENTSIf a student can’t locate his official USCIS documentation, the

student must request that the documents be replaced becausenoncitizens who are 18 years and older must have immigrationdocumentation in their possession at all times while in the UnitedStates. Requests for replacement documents should be made to theUSCIS District Office that issued the original documents.

The student will be asked to complete a Form I-90, “Application toReplace Alien Registration Card” or a Form I-102, “Application forReplacement/Initial Nonimmigrant Arrival-Departure Document.”PDF versions of these forms can be downloaded from the USCIS website at www.uscis.gov. A temporary I-94 may be issued while thereplacement documents are pending.

In cases of undue hardship, where the student urgently needsdocumentation of his status, the Freedom of Information Act (FOIA)allows him to obtain photocopies of the documents from the USCISDistrict Office that issued the original documents. The student cansubmit a Form G-639 to make this request or can simply send a letterto the district office. If he is not sure which district office issued theoriginal documents, he can submit the request to the field officenearest to his place of residence.

Exclusion from subsequentsecondary confirmation34 CFR 668.133(b)

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CITIZEN NOT BORN IN U.S./NONCITIZEN NATIONAL

Certification ofBirth Abroad

Issued to U.S. citizensborn abroad. Must haveembossed seal of the State

Department.

Certificate of Citizenship

The Certificate of Citizenship isissued to persons who wereborn abroad of U.S. parent(s),who became citizens when theirparents were naturalized, orwho were adopted by U.S.parents.

U.S. PassportCan be used to document

citizenship for citizen born abroad.

For a noncitizen national, must bestamped “Noncitizen National”(Note that a passport issued byanother country may be used to

document permanent residentstatus if it has the endorsement

“Processed for I-551” and has acurrently valid expiration date.)

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PERMANENT RESIDENT/OTHER ELIGIBLE NONCITIZENI-94 Arrival-Departure RecordFor permanent resident status, must be stamped “Processed for I-551” with expiration dateor “Temporary Form I-551” with appropriate information filled in.

For other eligible noncitizens, must be stamped as Refugee, Asylum Status, ConditionalEntrant (before April 1, 1980), Parolee, or Cuban-Haitian Entrant. See pp. 23–25.

A revised version of theCertificate of

Naturalization is issued tocitizens who filed fornaturalization after

October 1, 1991.

Certificate ofNaturalization

The Certificate ofNaturalization

is issued to naturalized U.S.citizens.

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PERMANENT RESIDENT

Alien RegistrationReceipt Card I-151(two versions, front and back)

Issued prior to June 1978 topermanent residents. Nolonger issued but validindefinitely. Often referredto as a “green card” thoughit is not always green.

Resident Alien CardI-551(three versions, front only)

Issued to permanentresidents. The I-551 is arevised version of the I-151.Often referred to as a “greencard” though it is not alwaysgreen.

The “Conditional ResidentAlien Card” is an I-551 thatis issued to conditionalpermanent residents such asalien spouses. This card isidentified by a “C” on thefront and has an expirationdate on the back.